by Kevin Bliss
On March 28, 2018, a federal district court entered a summary judgment order that held Humanism was in fact a faith group that must be recognized by the North Carolina Department of Public Safety (DPS).
Kwame Jamal Teague, incarcerated at the Lanesboro Correctional Institution, continually asked prison officials to recognize Humanism as an approved faith. Humanism is a belief system that focuses on the value and importance of humans, and rational ways to solve problems, rather than on divine beings or spiritual forces.
The DPS maintains a list of approved faith groups and provides resources, time and space for each to worship in state prisons. The agency did not have a required number of practitioners, written standards or other requirements for recognition of faith groups; rather, acceptance of a particular faith appeared to be completely subjective.
DPS staff instructed Teague to fill out forms, answer questions, provide a contact person and supply other information as needed, yet maintained throughout that process that Humanism was not an acceptable faith.
Teague, represented by the American Humanist Association (AHA), filed a civil rights action seeking a declaratory judgment, permanent injunction, nominal fees and attorneys’ fees and costs. He sought to have Humanism recognized as an approved faith.
The DPS engaged in several stall tactics to dissuade Teague, including transferring him to another facility, alleging his claim was moot, arguing Teague had changed his religion and therefore no longer wanted to practice Humanism, stating he could receive pastoral visits and practice his faith on his own time and at his own expense, and swamping him with paperwork and delays.
The district court held that Teague’s transfer did not moot his claims. Mootness is only applicable where a transfer prevents the prisoner from encountering the same unconstitutional conditions (Teague had also sought damages, which can prevent mootness).
Additionally, the defendants argued the AHA lacked standing. However, the court held the organization represented at least eight other prisoners besides Teague and therefore had associational standing.
The district court found DPS officials had violated the Establishment Clause of the First Amendment, as they were engaging in activity that deliberately differentiated among different religions. Their arbitrary decision to recognize some faiths but not others fostered an excessive governmental entanglement with religion.
Further, the DPS had violated the Equal Protection Clause of the Fourteenth Amendment. Prison officials argued that differential treatment was due to legitimate penological interests, yet the court held the record of DPS’s refusals did not focus on space, security or size, but rather on the merits of Humanism as a faith group. In fact, one DPS document specifically said Humanism did not pose a security threat.
The district court therefore granted permanent injunctive relief in part. The DPS was ordered to recognize Humanism as a faith group and an option for prisoners to choose as their religion, and to allow Teague and other Humanist prisoners to meet in a study group on the same terms authorized for prisoners in other approved faith groups. The court also issued a declaratory judgment, finding the defendants had violated the Establishment and Equal Protection Clauses by refusing to recognize Humanism and allow prisoners to choose it as their faith.
Summary judgment was granted in favor of Teague and the AHA, and the district court awarded nominal damages of $1.00 plus attorneys’ fees and $5,905.25 in costs. See: American Humanist Association v. Perry, U.S.D.C. (E.D. NC), Case No. 5:15-ct-03053-BO.
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Related legal case
American Humanist Association v. Perry
|Cite||U.S.D.C. (E.D. NC), Case No. 5:15-ct-03053-BO|